Publishing a mill list became table stakes around 2018. Today almost every major buyer has one online. The lists look similar — name, group, country, lat/lon — and they're all incomplete in the same way: they tell you which mills a buyer has touched, not which mills matter to a buyer's exposure.
What a mill list doesn't tell you
- Volume — a buyer sourcing 200 tonnes/yr from a mill is not in the same position as one sourcing 200,000.
- Sourcing radius — the 50km radius around a mill is where deforestation risk actually lives, and it's almost never published.
- Smallholder share — mills with high smallholder intake have different risk profiles than fully integrated estates.
- Group structure — listing mill names without UBO is the same as a phone book without addresses.
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Major buyer mill lists analysed
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Published volume per mill
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Published sourcing radius
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Published UBO mapping
What real traceability looks like
A traceable supply chain is one where, for any tonne arriving at a refinery, you can name the mill, the estimated catchment, the dominant plantation profile, and the corporate parent. None of that is impossible — it's just not what mill lists were built to do.
"A mill list answers 'where did we buy from?'. Traceability answers 'whose forest are we actually exposed to?'."
Publishing the list was the first step. The next is publishing what the list actually means.